In the realm of corporate compliance, legal professionals have long placed their focus on the US Department of Justice’s—DOJ—document “Evaluation of Corporate Compliance Programs”. However, according to Josh Drew, Member of Miller & Chevalier, there’s an additional, perhaps overlooked, resource worth considering: Attachment C.
A document typically attached to Foreign Corrupt Practices Act (FCPA) resolutions, Attachment C provides specific guidance on what a defendant company needs to accomplish to establish and maintain an effective corporate compliance framework.
This guidance is manifested in a variety of the document’s sections, each honing in on its own perspective of corporate compliance. Sections include, but are not limited to, topics such as governance, risk assessment, policies and procedures, record-keeping, and internal controls.
Despite its attachment to FCPA resolutions, the guidance within Attachment C is by no means limited to companies facing foreign corrupt practices allegations. The standards and recommendations within the document provide valuable, comprehensive insights for any corporation seeking to fortify its compliance program.
For a comprehensive understanding of Attachment C, do visit the full analysis by the Society of Corporate Compliance and Ethics here.